Subject: URGENT Request for installation of (almost) TOTAL STORMWATER TREATMENT FACILITIES at Morris Lake in the new residential developments (several major projects are planned in phases)

From: "S.M. Mandaville"
Date: Wed, 20 Sep 2000 12:15:58 -0300 (ADT)

To: "Catriona Moir (Manager-Ecosystems and Risk Management Branch-NSDoE)" <MOIRKM@gov.ns.ca>

BCC: "John Theakston PEng (Env. Engr.-Ecosystems & Risk Management Branch-NSDoE)" <THEAKSJA@gov.ns.ca>, "Darrell Taylor (Environmental Analyst-Ecosystems Branch-NSDoE)" <taylordl@gov.ns.ca>

Thank you and this will be as brief as I am capable of making it, but I will be happy to provide further LIMNOLOGICAL justification if required either at your offices or at the Regional offices or anywhere else for hat matter. (there may be minor typos in this)

We have conducted considerable scientific studies of Moris Lake in Dartmouth, not just of Chemical Limnology, but also of Biological Limnology (includes Phycology and Sublittoral Benthic Macroinvertebrates). Our studies of Morris Lake are the MOST COMPREHENSIVE STUDIES OF ANY LAKE as far as I am aware of in Nova Scotia to date. We have ofcourse conducted the Predictive TP-modelling of the whole Cow Bay River watershed as well of which Morris Lake is a part of. None of the scientific work is hidden from the public (no secrets here at all), it is available through a COMBINATION, not either/or, of our Web files and local university libraries where we deposited some of our scientific Reports.

The only aspect we have not lodged anywhere in the public domain are the past construction-related turbidity tests, but they dont have a relevance once a project has completed the construction phase!

OUR FOCUSED and URGENT REQUEST: This is not (r) not a municipal HRM issue as we had stated emphatically numerous times, perhaps a 100 times (without exaggeration). HRM DOES NOT FEEL it is responsible for either the present or future water quality. THEY EMPHATICALLY FEEL it is the TOTAL responsibility of your Department under the Environment Act.

Hence WE RESPECTFULLY ASK THAT NO APPROVALS BE GIVEN BY YOUR REGIONAL OFFICE FOR ANY STORMWATER DISCHARGES directly or indirectly into Morris Lake UNLESS `ALMOST' TOTAL STORMWATER SYSTEMS ARE INSTALLED as part of the pre-approval processes.

We are aware that the proponents plan to implement liberal use of the Australian-developed CDS (Continuous Deflective Separation) units as part of their stormwater treatment scenario, which is an improvement from even the recent history at Portland Estates.

CDS units are superb devices but they are not (r) not meant for removal of small particulates with which most of the post-development urban pollutants are associated with (e.g., fertilisers, pesticides,
hydrocarbons, etc.). Many of the post-development (not construction related) pollutants are associated with particles less than 100 microns, many times less than 50 microns, and a considerable amount are in dissolved form as well!!

CDS units were assessed by respected scientists and engineering researchers at the Monash University in Melbourne (http://www.catchment.crc.org.au/), Australia in addition to experts in Portland, Oregon and in Florida as well as in California. We have almost all the scientific and technical documents from them as well as from the United States, and these were all supplied to us by the CDS in the USA. Hence CDS manufacturers themselves do not claim that their units are an answer to everything!! CDS Technologies company senior staff from Australia and the USA are totally professional and do not make unsubstantiated claims!

Monash University scientists and engineering professors strongly recommend the COMBINATION of CDS units together, not either/or, with properly CONSTRUCTED URBAN (not natural) WETLANDS.

Three relevant references are:----

CDS Technologies. Binder titled, Storm Water Performance Review. CDS Technologies, Morgan Hill, CA, USA.

Herr, J.L., and Harper, H.H. Removal of gross pollutants from stormwater runoff using liquid/solid separation structures. Environmental Research & Design, Inc., Orlando, Florida, USA. 14p.

Wong, T.H.F., Breen, P.F., Somes, N.J.G., and Lloyd, S.D. 1999. Managing Urban Stormwater Using Constructed Wetlands. Cooperative Research Centre (CRC) for Catchment Hydrology and Department of Civil Engineering, Monash University, and Cooperative Research Centre (CRC) for Freshwater Ecology and Melbourne Water Corporation. Industry Report. 38p.

(there are many more references and you can access our related summary web file on urban stormwater treatment:--- http://www.chebucto.ns.ca/Science/SWCS/SWCS.html#uswt)

In addition, if NSDoE wants to know what are typical urban pollutants and relatively extensive references for same, you can refer to the following citations available via the libraries at Dalhousie and DalTech:--

Mandaville, S.M. 2000. Limnology- Eutrophication and Chemistry, Carrying Capacities, Loadings, Benthic Ecology, and Comparative Data. Soil & Water Conservation Society of Metro Halifax. xviii, Synopses 1, 2, 3, 13, and 14. 210p.

..... and other references .....
PS: By the way when a representative group headed by us met the Hon. Robbie Harrison in 1994, we asked for a guarantee of preserving Morris Lake. He had said Dianne Coish would get back us, which OFCOURSE she never did ! Hopefully, this would not happen with the present NSDoE staff!

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Shalom M. Mandaville (Professional Lake Manage.)
Chairman and Exec. Director
Soil & Water Conservation Society of Metro Halifax

(i) Homepage:
http://www.chebucto.ns.ca/Science/SWCS/SWCS.html

*Support aggressive monitoring for possible changes in "Biodiversity" using Benthic Macroinvertebrates in Freshwaters pre-&-post-development inclusive of major residential projects by the application of simple Rapid Bioassessment Protocols (RBPs) of the Ontario Ministry of the Environment (Dr. Keith Somers et al); Environment Canada-EMAN (Dr. David Rosenberg et al); the USEPA Biological Monitoring manuals (Dr. Michael Barbour et al); the NY State Dept. of Environmental Conservation (Robert Bode et al); and from the University of Guelph (Prof. Dr. Gerrie Mackie's upcoming `lead' text book)*


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